The European Commission has published draft legislation that includes food safety culture.

A revision of Regulation (EC) No 852/2004 on food hygiene also covers allergen management, and redistribution of food.

The Codex Alimentarius Commission is expected to adopt a revision of its standard on General Principles of Food Hygiene in the next few months. This update introduces the food safety culture concept as a general principle. Food safety culture’s aim is to increase awareness and improve the behavior of employees in establishments.

Considering the change of this standard and expectations of consumers and trade partners that food produced in the EU complies with such a standard, it is necessary to include general requirements on food safety culture in EU regulation, according to the EU Commission.

The draft introduces requirements on good hygiene practices to prevent or limit the presence of substances causing allergies or intolerances in equipment, conveyances, and/or containers used for harvesting, transport, or storage of foodstuffs.

Ambiguous and involved costs
Feedback on the food safety culture part of the plans, which closed this week, has been mixed with most concerns raised by industry while academia welcomed the draft.

Part of the new legislation asks management and all employees of businesses to commit to an appropriate food safety culture which includes a clear distribution of responsibilities, appropriate training, and supervision, and verifying controls are performed timely and efficiently and documentation is up to date.

Independent Retail Europe, which represents groups of independent retailers, said this was ambiguous and the commitment should be linked to the implementation of Hazard Analysis and Critical Control Points (HACCP) requirements.

“Putting in place a culture of food safety is more important than ever in the time of COVID-19, but it should be based in concrete measures such as ensuring that appropriate resources are spent on the cleaning and the preparation of stores during regular working hours.”

The text also states “implementation of food safety culture shall take account of the nature and size of the food business”.

The group said this wording may be interpreted as allowing for a less ambitious level of food safety commitment for smaller businesses.

“The commitment to food safety should be the same for all operators – from hypermarkets to farmers’ markets.”

COCERAL, the European association representing the trade in cereals, rice, feedstuffs, oilseeds, olive oil, oils and fats, and agro supply, said global harmonization was key to a level playing field and developing the same culture worldwide.

“At the same time, all the points listed are already part of the current business mindset and operations, under the HACCP approach. The Commission must consider the real costs for the involved economic players, bearing in mind particularly small and medium enterprises, and try to avoid imposing an economic burden on an already heavily hit sector in the COVID-19 aftermath.

“COCERAL deems that for the sake of harmonization, official control authorities at the member state level should adopt a common framework to evaluate compliance against the food safety culture requirements.”

The association said guidance would be beneficial to the food sector and it was important not to impose different requirements on businesses in different countries.

Industry pushback vs a step forward
FoodDrinkEurope, the European food and drink industry’s organization, said provisions on food safety culture look too vague to enforce in a reasonable manner.

“In our opinion, there is no expectation among either third countries or consumers that companies have a defined food safety culture, verified by the authorities. There is currently no agreement within the private standards on how food safety culture can be verified.”

The Liaison Centre for the Meat Processing Industry in the EU (CLITRAVI) said the Commission was introducing a topic without knowing the implications and the meat processing industry in Europe was “very concerned” about including such requirements in the regulation.

“CLITRAVI underlines the point that work on food safety culture, which originates from the industry’s privacy standards, is still in process, as these are matters that have to do with human behavior and are not a technical requirement such as the HACCP.”

The group urged the EU Commission to withdraw the proposal which is planned for adoption in the third quarter of 2020 adding any pending legislation should await Codex work.

Bert Popping, of FOCOS – Food Consulting Strategically, said the addition of the food safety culture concept to existing rules on food hygiene is a significant step forward.

“However, the wording…is vague and will give rise to misinterpretation and confusion. It is recommended to precise the wording used prior to passing the proposal.”

Pieternel Luning of Wageningen University said the amendment creates opportunities and will not be an extra burden.

“The amendment will enhance awareness on the importance of food safety culture. Paying attention to the food business’ food safety culture will not only benefit the assurance of safe food but will also lead to more committed and motivated employees and overall better business performance,” she said.

“The scientific community in collaboration with the food industry has a great challenge to develop tools and improve road maps for enhancing the food safety culture tailored to the specific context of the food business operators in the food supply chains.”

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